After 70 years the arm's length principle seems to have reached the limits of its development. The OECD Guidelines 1995 should provide for a better balance between, on the one hand, the anti-tax-avoidance emphasis of, in particular, the United States and, on the other hand, the German sound business manager criterion. Because of the difference in opinion on the application of the arm's length principle and problems with its practical application, a study of the possible alternatives to arm's length pricing should be undertaken

After 70 years the arm's length principle seems to have reached the limits of its development. The OECD Guidelines 1995 should provide for a better balance between, on the one hand, the anti-tax-avoidance emphasis of, in particular, the United States and, on the other hand, the German sound business manager criterion. Because of the difference in opinion on the application of the arm's length principle and problems with its practical application, a study of the possible alternatives to arm's length pricing should be undertaken